Privacy Policy

1. Introduction

EA SOFT LTD ("we", "us", or "our") operates the FamilyOFX platform (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. We are committed to protecting your privacy and handling your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Company Information

FamilyOFX is a brand operated by EA SOFT LTD, a company registered in the United Kingdom. For any privacy-related questions or concerns, please contact us at:

3. Information We Collect

We collect information that you provide directly to us and information that is automatically collected when you use the Service:

3.1 Information You Provide

• Account information (name, email address, password)
• Financial and investment data you input into the Service
• Documents and files you upload
• Contact information and relationship data
• Payment information (processed by third-party payment processors)
• Any other information you choose to provide

3.2 Automatically Collected Information

• Device information (IP address, browser type, operating system)
• Usage data (pages visited, features used, time spent)
• Log data (access times, error logs)
• Cookies and similar tracking technologies

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process payments and manage subscriptions
• Authenticate users and manage accounts
• Sync email and calendar data (via Nylas with Google and Microsoft)
• Provide AI-powered features and data processing (via Anthropic)
• Analyze usage patterns and improve user experience
• Send service-related communications
• Comply with legal obligations
• Detect and prevent fraud or abuse

5. Third-Party Services and Data Sharing

We share your information with third-party service providers who perform services on our behalf. These third parties are contractually obligated to protect your information and use it only for the purposes we specify:

We do not sell your personal information to third parties. We only share information as necessary to provide the Service and as described in this Privacy Policy.

6. Legal Basis for Processing (UK GDPR)

Under UK GDPR, we process your personal data based on the following legal bases:

• Contractual necessity: To provide the Service you have requested
• Legitimate interests: To improve our Service, prevent fraud, and ensure security
• Consent: Where you have provided explicit consent for specific processing activities
• Legal obligation: To comply with applicable laws and regulations

7. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Secure hosting infrastructure

8. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When you delete your account, we will delete or anonymize your personal information, subject to any legal retention requirements.

9. Your Rights (UK GDPR)

Under UK GDPR, you have the following rights regarding your personal data:

• Right of access: Request a copy of your personal data
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your personal data
• Right to restrict processing: Request limitation of how we process your data
• Right to data portability: Request transfer of your data to another service
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent where processing is based on consent

To exercise any of these rights, please contact us at etienne@ea-soft.com. We will respond to your request within one month.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Service and store certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

11. International Data Transfers

Your information may be transferred to and processed in countries outside the UK, including the United States and other jurisdictions where our third-party service providers operate. We ensure that appropriate safeguards are in place to protect your data in accordance with UK GDPR requirements, including standard contractual clauses where applicable.

12. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. You are advised to review this Privacy Policy periodically for any changes.

14. Complaints

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection authority:

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at: